Privacy Policy

To explain how we process and collect your personal information:

We want you to make informed choices about the use and processing of Personal Data. This is why we created this website: to provide you, through various methods and procedures, with relevant information about how Personal Data is used.
Where we believe you require specific details, we will provide them at the appropriate time.
We are happy to answer any questions you may have and to provide any clarifications you require, subject to any limitations imposed by law. You can reach us by email at the address below: info@sterlingsteward.net

Personal Data will be used only for the purposes set out in this Policy.

We process Personal Data for a range of purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining and delivering the Services, meeting regulatory or legal obligations, and carrying out administrative and business activities related to the Services.
We also process Personal Data to better understand your preferences and needs.

To provide effective tools for safeguarding your rights regarding Personal Data

We maintain substantial resources to support the exercise of your rights. Contact us at any time to request access to your personal data. We will correct or delete it, or stop using it for specific or general purposes, upon request. We can also transfer your data to you or to a third party. We are equipped to accommodate your requests.

Protect Your Personal Data:

While we cannot guarantee absolute security of your Personal Data, we will continue to employ a range of methods and techniques to protect it.
This concludes our Privacy and Security Policy.

1. The Scope?

This Policy explains the types of Personal Data the Company collects on natural individuals and how it is processed, shared with third parties, secured, and otherwise handled.
This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or through a combination of additional information we hold or can access.
This Policy defines "processing" as any operation involving the use or collection of Personal Data, including the management, structuring, and storage of Personal Data.
Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly collect information from anyone under 18, and we do not knowingly permit such persons to use our services. If we learn that we have collected information relating to a child, we will delete it as quickly as possible.

2. What Personal Data Do We Hold About You?

We collect Personal Data when you access our Services and channels or visit our website. In some cases, we request this data directly from you. In others, we collect it by analysing how you use our Services or service channels, or by receiving it from our third-party partners.

You are not required to disclose personal information to us. However, if you choose not to provide certain information, we may be unable to deliver our Services or grant you access to the website.

You are not obliged to provide Us with any Personal Data. However, in certain circumstances, failure to supply Personal Data may prevent Us from delivering the Services or prevent you from accessing the website.

What Personal Data Do We Collect? When you visit our website, we collect the following personal information about you:

This includes information about your online activity log, data about your traffic (including IP address, date of access, and time of access), the language you used, software crash logs, the type of browser used, and information regarding the device you utilized. This information is not personal data and cannot be used to identify you.
Personal Data We receive from you: any personal data you provide to Us at your own choice when you connect with an online trading platform of a third party through Us.
Personal data you provide specifically to third-party platforms to facilitate trade: this includes your full name, address, phone number, and email address.

5. Legal Basis and Purposes for Processing Personal Data

6. Transfer of Personal Data to Third Parties We may share your personal data with third parties where necessary to provide our Services, meet legal obligations, or as otherwise described in this policy. We require any third party receiving your personal data to protect it in accordance with applicable data protection standards and to use it only for the purposes for which it was disclosed. We do not sell your personal data to third parties for their own marketing purposes.

The Company may also share Personal Data with third-party companies that provide services to us, including hosting and storage providers, IP address information, and analysis of user experience.
You may also ask us to provide specific Personal Data regarding you to third-party trading platforms. In these instances, we will provide the Personal Data you have given us to third-party trading platforms. Use of your Personal Data by these platforms is subject to their own privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with related entities or business partners. This provides the Company with the resources needed to enhance and improve the products and services it offers its customers.
Where necessary to safeguard the rights of third parties or protect assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with potential investors, buyers, or lenders to the Company or any other company within the group in connection with a transaction such as the transfer or sale of assets belonging to the Company or any other group company, or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other business within the group.

7. Cookies and Third-Party Services

We may use third-party services, such as advertising partners or analytics providers, on our website. These companies may also use cookies or similar technologies.
Cookies are small text files placed on your device when you visit or access the website. We use cookies to gather information about your preferences and browsing habits, improve your user experience, remember your preferences, and tailor products and services to your interests. Cookies are also used for statistics and analytics.
Some cookies we use are session cookies. These are downloaded temporarily to your device and remain only until you close your browser. Other cookies are persistent, remaining on your device for a set period after you close your browser. Persistent cookies help the website recognize you as a returning user and allow you to return to the website more easily.

Types of Cookies:

We may use them according to their purpose:

ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of Your Personal Data

The Company will retain Personal Data for as long as necessary to fulfill the purpose described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and orders.
We will share your information with third-party trading platforms for a period of 12 months. If you consent, we will continue sharing your data for a further 12-month period.
We regularly review the Personal Data we hold to ensure it is no longer retained once it is no longer needed.

9. Transfers of personal data to a third country or international organisation

10. Security of Personal Data We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures are reviewed and updated as necessary to reflect changes in technology and identified risks. While we take reasonable steps to safeguard your personal data, no method of transmission or storage over the internet is completely secure. We cannot guarantee absolute security of the information you provide to us. You are responsible for keeping your account credentials, passwords, and seed phrase confidential. We will never ask you to disclose your seed phrase, and you should never share it with anyone. Any loss of your seed phrase or credentials may result in permanent loss of access to your funds. If we become aware of a data breach affecting your personal data, we will notify you and relevant authorities where required by applicable law.

We have taken appropriate organizational and technical precautions to safeguard Personal Data, including measures to prevent its accidental or unlawful destruction, loss, or alteration.
We cannot guarantee that the security of your Personal Data will be maintained without error, and we accept no liability for intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.
Where legal or other obligations beyond our control require it, we may be required to disclose Personal Data concerning you to third parties, such as public authorities. We have no control over the security such third parties apply to your Personal Data in these situations.
Personal Data cannot be transferred over the web with complete security. The Company cannot guarantee the security of Personal Data you transmit to us over the internet.

11. Hyperlinks to Third-Party Websites

The website may contain links to third-party sites and applications. These are not supervised by the Company, and We are not responsible for how these websites or apps collect or process Personal Data. This Policy does not apply to actions taken through such sites or apps.
Before accessing or using any third-party website or app, We recommend that you read its privacy policy. We also advise caution before providing any Personal Data to them.

12. Modifications to this Policy

Before accessing or using any third-party website or app, We recommend that you read its privacy policy. We also recommend that you consider carefully before providing any Personal Data to third parties.

13. Your rights with respect to your personal information

You are entitled to request that We verify the accuracy of Personal Data collected regarding you, rectify any mistakes, and delete Personal Data no longer required by Us. You may also restrict the scope of processing of your Personal Data.
If you are a resident of the EEA, please refer to this page:
These rights apply with respect to the information you provide in relation to your Personal Data. You may request to exercise these rights by writing to the email address below.
Access rights
The Company is able to verify the accuracy of Personal Data being processed about you. Where this is confirmed, you are able to access your Personal Data.
The Company will supply an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. Data will be made available electronically upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would adversely affect the rights and freedoms of another party, the Company may refuse to comply with the request or limit its capacity to fulfill it.
Right to rectification
The Company will rectify inaccurate Personal Data. You are entitled to demand that any incomplete Personal Data concerning you be rectified, taking into account the purpose of processing.
Right to Erasure
The following reasons apply: (a) Personal Data are no longer required for the purpose for which they were collected or processed; (b) you withdraw consent and no legal basis for processing remains; (c) you object, on grounds relating to your particular situation, to processing of Personal Data based on legitimate interests pursued by Us or a third party; (d) Personal Data are unlawfully processed; or (e) Personal Data must be erased to comply with a legal obligation to which the Company is subject.
This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union law or Member State law; or (b) to establish, exercise, or defend legal claims.
Processing restrictions
If you dispute the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data.
Where you have requested that processing be restricted, Personal Data may only be retained with your consent, or in order to establish, exercise, or defend legal claims, to protect the rights of another natural person, or for reasons of significant public interest within the European Union or a Member State.
Right to data portability
Where processing is carried out by automated means and is based on your consent or on a contract to which you are party, you have the right to receive the Personal Data you have provided to the Company.
You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where this is technically feasible. Exercising the right to data portability does not affect your rights under the right to erasure. The right to data portability does not affect the rights or freedoms of others.
Right to object
You have the right, at any time, to object to processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This includes profiling based solely on such legitimate interests. Where the Company demonstrates compelling legitimate grounds for the processing, it may continue unless you can show that your rights, freedoms, and interests override those grounds, or unless the processing is necessary for the exercise, establishment, or defense of legal claims.
With regard to direct marketing, you have the right, at any time, to object to processing of Personal Data concerning you.
Right to withdraw consent
You may withdraw your consent to Our processing of Personal Data about you at any time. This will not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal.
You are entitled to lodge a complaint with your supervisory authority.
You may lodge a complaint with a supervisory authority established by a Member State to safeguard the fundamental rights of individuals with regard to the processing of Personal Data within the European Union.
The laws of the European Union and Member States may limit your rights in relation to Personal Data concerning you, as described in this section 13.
We will provide the information requested under the rights set out in section 13 within one month of receiving your request. This period may be extended by up to two months where necessary, depending on the nature and number of requests. We will notify you of any extension, and the reasons for it, within one month of receiving your request.
Provided this is consistent with section 13, information requested under your rights in that section will be provided free of charge. Where a request is unfounded or excessive, particularly if repetitive, We may charge a reasonable fee to cover the administrative cost of providing the information or taking the action requested, or may decline to act on the request.
Where We have reasonable doubts about the identity of the person submitting a request, the Company may request further information to confirm it.